All posts by Clifford E. Kirsch, Editor

Eversheds Sutherland With more than 25 years of experience, Cliff regularly counsels clients on the design and distribution of investment products including wrap-fee programs and other advisory products, mutual funds, bank collective investment funds and insurance products. He also focuses on issues related to the design and implementation of compliance programs at financial services firms.

Regulatory

FHFA’s Pulte Orders Fannie, Freddie to

June 27, 2025 Clifford E. Kirsch, Editor Leave a comment

Consider Crypto as a Mortgage Asset

From FiSolve, Federal Housing Finance Agency Director William Pulte shared via social media post his instructions to Fannie Mae and Freddie Mac to prepare their businesses for counting cryptocurrency as an asset on mortgage applications. Pulte said the move was “in keeping with President Trump’s vision to make the United States the crypto capital of the world.” In his order, he said crypto is an emerging asset class that may offer an opportunity to build wealth outside of the stock and bond markets. Read more here.

Compliance, Enforcement, International, Regulatory, Standard of Care

Financial Action Task Force Identifies Jurisdictions with AML and other Deficiencies

June 27, 2025 Clifford E. Kirsch, Editor Leave a comment

At its June 2025 plenary meeting, the Financial Action Task Force (FATF) updated its global watchlists for jurisdictions with deficiencies in anti-money laundering, terrorist financing, and weapons proliferation controls. The British Virgin Islands and Bolivia were added to the list of “Jurisdictions Under Increased Monitoring,” while Croatia, Mali, and Tanzania were removed. Iran, North Korea, and Burma remain classified as “High-Risk Jurisdictions Subject to a Call for Action,” with Iran and North Korea facing countermeasures and Burma subject to enhanced due diligence. FinCEN advises U.S. financial institutions to review these changes when assessing risk and to ensure compliance with U.S. AML regulations, especially regarding correspondent accounts with foreign financial institutions and obligations under U.S. sanctions and the Bank Secrecy Act. Institutions must not engage in indiscriminate de-risking but are expected to apply risk-based controls and file Suspicious Activity Reports when warranted. Read more here.

Compliance, Regulatory, Standard of Care

SEC Extends Compliance Date on Broker-Dealers Daily Reserve Computation Requirement

June 27, 2025 Clifford E. Kirsch, Editor Leave a comment

From FiSolve, the Securities and Exchange Commission extended the compliance date for the amendments to Rule 15c3-3 (the broker-dealer customer protection rule) from December 31, 2025 to June 30, 2026. The amendments require certain broker-dealers to increase the frequency of required reserve computations under Rule 15c3-3 from weekly to daily. The SEC announced the extension is designed to provide more time for broker-dealers to make any necessary systems or operational changes to implement a daily computation requirement and test their new daily processes for compliance. Read more here.

Compliance, Regulatory

SEC Division of Economic and Risk Analysis Publishes Comprehensive Broker-Dealer Study

June 27, 2025 Clifford E. Kirsch, Editor Leave a comment

From FiSolve: the SEC released a study conducted by its Division of Economic and Risk Analysis regarding broker-dealer activity. As of 2024, there were approximately 3,340 broker-dealers with total assets of approximately $6.4 trillion. The number of broker-dealers declined by approximately 30% from 2010 to 2024, but assets grew by approximately $1.7 trillion. These results show a trend of industry consolidation, with a declining fraction of market participants responsible for a larger asset pool by the end of the sample period (2010-2024). The study also contains information on revenues and expenses. The industry has achieved greater levels of profitability during the most recent five years. The report includes other interesting areas of information relating to revenues, expenses, employees and more. Read more here.

Compliance, Enforcement, International, Regulatory, Standard of Care